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August 19, 2013

12 Best Practices for Choosing the Right Tactical Allocation Strategy

The Center for Due Diligence sounds off on the problems TAA presents

Looking for ways to stabilize returns and manage downside risk, plan sponsor and investment advisor interest in tactical asset allocation strategies has increased, according to the Center for Due Diligence. This presents unique challenges for plan fiduciaries when evaluating the actual benefits of TAAs, mainly centered on the complexity and diversity of TAA strategies that are available to plan investors.

A white paper produced by the center and written by Marcia Wagner and John Sohn of The Wagner Law Group runs through a number of best practices to consider when implementing the strategies.

In contrast to the passive approach adopted in strategic asset allocation strategies, the authors note, TAA uses an actively managed approach to a portfolio’s allocations based on current market conditions. 401(k) plans and other similar plans with participant-directed investments often include target-date or target-risk investment options utilizing a TAA strategy of some kind.

2). Tactical constraints. Plan fiduciaries should ensure that the asset allocation investment has a strategic asset allocation (SAA) with a tactical overlay subject to reasonable constraints, ensuring that tactical changes comply with the regulatory mandate to achieve long-term appreciation and preserve capital.

3). TAA’s impact on diversification. Plan fiduciaries should gather information concerning the extent to which tactical changes may cause the investment’s portfolio to become less diversified.

4). Frequency of changes. Plan fiduciaries should perform enhanced due diligence on a TAA advisor that utilizes frequent tactical allocation changes (e.g., multiple changes per quarter), and confirm that each tactical change is being made in a disciplined manner in accordance with its investment theories.

5). Factors given appropriate consideration. Plan fiduciaries should gather information concerning the objective measures (e.g., capital market data, governmental policies) that are being given appropriate consideration by the TAA advisor for purposes of its tactical changes.

6). Retired participants. Plan fiduciaries should gather information on the extent to which the TAA advisor gives appropriate consideration when making tactical changes to the fact that retired participants, as applicable, are taking current distributions from the asset allocation investment.

7). Expertise and experience. Plan fiduciaries should consider the professional qualifications of the TAA advisor (and outsourced service providers, such as technical overlay professionals, if any) as well as its specific TAA-related expertise and experience.

9). Contrarian-like tactics. Plan fiduciaries should perform enhanced due diligence for any TAA advisor that utilizes contrarian-like tactics (based upon identifying “inflection points” and directional changes in the markets) and gather information on the potential risk of loss associated with such tactics (e.g., any constraints on tactical deviations from target allocations).

10). Plan-level disclosures. Plan fiduciaries should review the disclosures provided by the plan recordkeeper under the 408(b)(2) regulations for designated investment alternatives (DIAs), as well as the TAA advisor’s ADV brochure (assuming the TAA Advisor is a registered investment adviser) to gather relevant information concerning the TAA advisor and its TAA strategy.

12). Average participant standard. Plan fiduciaries should consider including a brief description of the TAA strategy and its associated risks in the required DIA and QDIA disclosures for participants to help ensure that such disclosures can be understood by the plan’s “average” participant as required under DOL rules.

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